Privacy Policy


1. The Basics

A. About Us

Dyson Capital Management Ltd (DCM) is primarily an investment manager providing discretionary investment management to its clients and also provides a consulting service under the trading name Dyson Capital Consulting.

B. Key Terms

In this privacy policy, these terms have the following meanings:

"Service" is any service that DCM provides to its clients

"Contact" is a person who is not a client but has expressed an interest in being kept up to date with DCM

"Client" means any person that has signed our investment management agreement or has requested some consultancy service from us.

"Personal Information" means any information that identifies or can be used to identify an individual, a Contact, or a Cilent. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.

"Website(s)" means any website(s) we own and operate (such as www.dysoncapitalmanagement.com) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.

"Visitor" means any person who visits any of our Websites.

"you" and "your" means, depending on the context, either a Contact, or a Client.

2. Privacy for Clients and Contacts

This section applies to the Personal Information we collect and process from a Client or potential Client through the provision of the Services. If you are not a Client, the Visitors or Contacts section of this policy may be more applicable to you and your data.

A. Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you including financial information. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, send us an email, or communicate with us in any other way.

We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as required to provide our services.

(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We may use cookies and other tracking technologies to collect some of this information. If you do not consent to our use of cookies, they can be turned off via your browser.

(iii) Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.

B. Use of Personal Information

We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

  • To bill and collect money owed to us by you.
  • To send you relevant information about our service.
  • To communicate with you about your account and provide customer support.
  • To ensure that you are eligible to use our investment management service as required by the Financial Conduct Authority
  • To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
  • To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
  • To prosecute and defend a court, arbitration, or similar legal proceeding.
  • To respond to lawfli requests by public authorities, including to meet national security or law enforcement requirements.
  • To provide, support and improve the Services. For example, this may include sharing your or your Contacts’ information with third parties in order to provide and support our Services or to make certain features of the Services available to you.
  • To provide suggestions to you.
  • Combined information. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.
  • Other purposes. To carry out other legitimate business purposes, as well as other lawfli purposes about which we will notify you.

C. Cookies and Tracking Technologies

We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf. These web beacons track certain behaviour such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to measure the performance of your email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.

D. Other Data Protection Rights

You may have the following data protection rights:

  • To access, correct, update or request deletion of Personal Information. DCM takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. Please contact info@dysoncapitalmanagement.com to request/update/delete the personal information that is held.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.

3. General Information

A. How We Share Information

We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Contacts and Clients unless otherwise indicated):

(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.

(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.

(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganisation, or acquisition.

(v) Any other person with your consent.

B. Legal Basis for Processing Personal Information(EEA Persons Only)

If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.

If you are a Client, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.

Where required by law, we will collect Personal Information only where we have your consent to do so.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.

C. Your Choices and Opt-Outs

Members and Visitors who have opted in to our information emails can opt out of receiving emails from us at any time by clicking the "unsubscribe" link at the bottom of our email messages.

Also, all opt-out requests can be made by emailing us at info@dysoncapatalmanagement.com

Our Security

We take appropriate and reasonable technical and organisational measures to protect Personal Information from loss, misuse, unauthorised access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

DCM accounts require a username and password to log in. Members must keep their username and password secure, and never disclose it to a third party. Because the information in a Client’s account is so sensitive, account passwords are hashed, which means we cannot see a Member’s password. We cannot resend forgotten passwords either. We will only provide Members with instructions on how to reset them.

E. Retention of Data

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:

  • Whether we have a legal or contractual need to retain the data.
  • Whether the data is necessary to provide our Services.
  • Whether our Clients or Contacts wolid reasonably expect that we wolid retain the data until they remove it or until their accounts or agreements are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

F. Changes to this Policy

We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.

G. Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please email us at info@dysoncapitalmanagement.com